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RESPONSE TO WRITTEN TESTIMONY AT EUGENE CITY COUNCIL PUBLIC HEARING ON THE MWMC WASTEWATER FACILITIES PLAN AND SDC METHODOLOGY <br /> <br />Improvement Fee (Bottom of Page 12 through Middle of Page 16) <br /> <br />The development of the improvement fee methodology was presented and discussed at <br />numerous SDC Citizen Advisory Committee (CAC) sessions from January through March <br />2004 and was modified to incorporate their input. The CAC provided a majority <br />recommendation on the "Existing and future facility cost allocation" topic (see March 31, <br />2004, memorandum from CAC to MWMC.) <br /> <br />The June 13, 2004, HBALC letter attempts to discredit the SDC Methodology by stating that <br />the capacity that has been identified to serve growth in Table C-1 of the Methodology is not <br />used in the SDC rate calculation. However, the capacity needs are used directly in the SDC <br />rate calculation as illustrated by: <br /> <br />· Presentation to the CAC at the February 25, 2004, meeting (see meeting minutes) <br />· Presentation to the CAC at the March 10, 2004, meeting (see meeting minutes) <br />· Packet provided to the Eugene City Council June 14, 2004, Public Hearing <br /> <br />These examples demonstrate that the capacity needed to serve growth for each capacity <br />parameter as presented in Tables C-1 and C-3 of the SDC Methodology is explicitly used in <br />the SDC rate calculations. <br /> <br />From the middle of page 13 through the middle of page 16, the June 13, 2004, HBALC letter <br />discusses a specific project - Headworks Expansion. A similar discussion was presented in <br />the May 3, 2004, HBALC letter addressed to MWMC. CH2M HILL responded with a <br />written point-by-point response to the May 3rd letter. This response was submitted into the <br />public record at the May 6, 2004, MWMC meeting and pointed out many flaws in the <br />HBALC assessment. One error that the Home Builder's representative continues to make is <br />to attempt to add average flow capacity to peak flow capacity to obtain a "total capacity." <br />As we have previously indicated, this addition is meaningless and adds unnecessary <br />confusion to the issue of MWMC's SDC discussion. The Home Builder representative's <br />approach would be analogous to mixing 1 cup of water with 3 cups of oil and saying you <br />have 4 cups of wateroil. Well of course you don't have wateroil you have a mixture of 1 cup <br />water and 3 cups oil. It is inappropriate to add Average Flow and Peak flow together and <br />say you have "Total Flow;" the sum has no meaning. The example presented in the HBALC <br />attempts to do this math and it does not make sense. The units of measure are the same, <br />million gallons per day (mgd), but what you are measuring is different. As indicated <br />previously, we pointed this out in detailed response to the May 3, 2004, HBOLC letter, <br />which contained numerous errors and mis-informed statements. <br /> <br />Accordingly, as noted in our letter dated June 14, 2004, we have deferred to MWMC legal <br />counsel with respect to compliance with legislative requirements for fee adoption. <br /> <br />June 14, 2004 Letter from Home Builders Association of Lane County, <br />Re: MW-MC Facility Plan and SDC List <br /> <br />Page 3, first full paragraph, second sentence: 'The cost of the project allocated to growth <br />are not based on the actual capacity needed to serve growth ' <br /> <br />C:\DOCUMENTS AND SETTINGS\CEEXELI--~LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK3B~AIS HBALETTERSFROMCH2 FINAL DRAFT 061804.DOC 3 <br /> <br /> <br />